The usual elements of a complaint filed under the FHA and ADA are:
- A lengthy and unnecessary recital of the legislative history of the law, including all kinds of statements about the historical oppression of those with disabilities,
- A broad allegation that the plaintiff visited the defendant’s location, without details that might make the claim verifiable, and
- A series of broad statements about violations of the law that, once again, lack any detail that would make them verifiable.